1. Introduction

    Modern slavery – including slavery, servitude, forced or compulsory labour, and human trafficking – is a serious violation of human rights. Clever Centre Ltd, the company behind Vortextract, takes a zero-tolerance approach to these practices. We are committed to ensuring modern slavery has no place in our operations or supply chains, and we expect the same from our suppliers, partners, and contractors.

    This statement is published in line with section 54(1) of the UK Modern Slavery Act 2015 and outlines the steps taken by Clever Centre Ltd during the financial year ending 30 April 2025 to prevent modern slavery and human trafficking.

    1. Our Mission and Values

    Clever Centre Ltd is an independent, values-led organisation dedicated to tackling the climate emergency. Through Vortextract, we deliver cutting-edge energy-saving technologies, technical assurance, research, and communications support to help businesses reduce energy costs, cut carbon emissions, and transition to a cleaner future.

    Our values guide our approach to modern slavery prevention as much as they do to climate action:

    • Expertise & Integrity – acting with honesty, transparency, and professionalism.
    • Collaboration – working with businesses, suppliers, and stakeholders to drive collective progress.
    • Innovation – embracing change to improve how we operate responsibly.
    • Inclusivity & Support – ensuring a just and fair transition where all businesses and communities can benefit.
    • Determination – applying the same commitment to human rights as we do to achieving net zero.
    1. Our Supply Chains

    Our supply chain includes:

    • Technology and hardware suppliers for heating-system optimisation and related energy solutions.
    • Research and consultancy partners.
    • Office, IT, and professional service providers.

    Most of our suppliers are UK-based, but we recognise that risks may exist where components or services are sourced internationally. We take a proportionate, risk-based approach to managing these relationships.

    1. Policies and Governance

    We operate a framework of policies to safeguard against modern slavery:

    • Anti-Slavery & Human Trafficking Policy – setting out our zero-tolerance approach.
    • Procurement & Supplier Policy – embedding responsible and sustainable procurement principles.
    • Whistleblowing Policy – allowing concerns to be raised confidentially.
    • Code of Conduct – setting standards for ethical behaviour across staff and suppliers.
    • Safeguarding Policy – protecting vulnerable people we may work with in our projects.
    1. Due Diligence and Risk Management

    We identify and manage modern slavery risks through:

    • Risk assessments of new and existing suppliers.
    • Modern slavery clauses in supplier contracts.
    • Ongoing supplier reviews and monitoring, particularly for higher-risk categories.
    • Right-to-work checks for all employees, contractors, and associates.
    1. Training and Awareness

    We provide colleagues with training on how to identify, prevent, and report suspected modern slavery. Awareness of our zero-tolerance approach is built into staff induction, procurement processes, and supplier engagement.

    1. Reporting and Escalation

    Concerns can be reported through internal management channels or our Whistleblowing Officer. Where necessary, external mechanisms such as the Modern Slavery Helpline are also available. All concerns are taken seriously, investigated promptly, and escalated to the Board where appropriate.

    1. Commitments for 2025/26

    Over the coming year, Clever Centre Ltd will:

    1. Extend modern slavery training to all staff with procurement or supply chain responsibilities.
    2. Strengthen due diligence checks for high-risk suppliers.
    3. Hold at least one supplier engagement session on ethical labour practices.
    4. Review policies annually to align with evolving best practice.
    1. Approval

    This statement has been approved by the Board of Clever Centre Ltd and will be reviewed annually.

    Signed:
    Charles Ross
    Director, Clever Centre Ltd
    Date: 13th September 2025